California Health & Rescue Training

Confined Space Rescue in Roseville

In May 1996 Roseville Fire Department opened its state of the art Confined Space Rescue training center. The center is just one component of the 3.5 million dollar Fire Training facility that makes quality fire and rescue training a reality in the southern Placer County area of California.

The Confined Space Rescue facility has been certified by State Fire Training and is designed to provide the most realistic training possible for fire service personnel and industrial rescue team members. It provides students an environment to perform rescues in various props that simulate or duplicate those that they may be expected to respond to. The facility allows live rescues to be performed in a controlled low risk environment.

The Props
The facility includes all of the props required by State Fire Training for certification, plus additional props to provide a challenge for even the more advanced rescue team members. Included in the facility is a fifty one hundred gallon upright tank with top and horizontal man-ways and pipe tree. This prop is used in numerous ways to simulate a full array of industrial applications including lock-out/tag-out procedures. An in pipe rescue prop is provided to simulate rescues in horizontal pipe-ways. An above ground grain hopper with a top man-way and tapered bottom cross-section is provided to simulate rescues in a grain or bottom dump environment. Multiple below grade vaults connected underground by piped duplicate the numerous below grade vaults that every jurisdiction must deal with. A railroad tank car with three top man-ways and catwalk is provided to perform rescues in, and a 30 foot deep vertical shaft is used to replicate the many shaft rescues that have occurred. In addition to the props provided at the facility, the facility will commonly use sites throughout Roseville to test the mettle of students. Sites include a 60 foot deep storm water lift station which includes a 25 foot horizontal shaft under the roadway, as well a sewage lift stations and industrial sites throughout the city.

The Equipment
Roseville Fire Department and the faculty of the Confined Space Rescue program pride themselves in giving the students an opportunity to use a large array of the equipment available for confined space rescue. Manufacturers of equipment are always looking for a way to market and test their equipment. We give the manufacturers a forum to do both, in turn we are able to provide our students with the opportunity to use some cutting edge equipment. Students finish the class knowing what equipment will work in the specific applications they may face when they return home.

Students provide their own personal protective equipment, but all other equipment is provided in class. Equipment inventories include atmospheric monitors, ventilation equipment, respiratory protective equipment, including SCBA and umbilical air systems, communications equipment ranging from rope signals to hardwire communications, lock-out/tag-out equipment, lowering and retrieval equipment, including tripods and winches, harnesses, SKED litters, LSP halfbacks, wristlets, etc. Also included is a complete rope and hardware inventory, ladders and lighting equipment.

The Curriculum
The curriculum being used is the State Fire Training Division's Confined Space Rescue "Awareness" and Confined Space Rescue "Operational" programs. These programs have been reviewed by the usual State Fire Boards as well as CAL-OSHA. Training that meets these guidelines will assure that you have received a standard level of instruction that will provide the documentation you want during a post incident investigation. Good Confined Space Rescue training is a well balanced blend of classroom didactics and hands on manipulative exercises. Our priority is for students to leave understanding the hazards of confined spaces, the equipment and techniques needed to perform confined space rescue, and the regulations affecting their operations. This curriculum and our program meet this objective. In addition, it gives the student the ability to adapt to situations they may face within their own jurisdiction.

The Faculty
The best facility and curriculum is nothing unless you have quality instructors to present the information. The Confined Space Rescue program at Roseville Fire Department is instructed by a faculty the represents a cross-section of California's finest rescue instructors. With the Senior instructor being the author of the Confined Space Rescue "Awareness" program, a member of the curriculum development team for the Confined Space Rescue "Operations" program and coordinator of the Technical Rescue Team in Roseville. Other instructors include a U.S.A.R. coordinator from Santa Fe Springs Fire Department in Los Angeles County, and members of the Roseville Fire Department Technical Rescue Team.

The Objective
Without proper training, confined space operations, and especially confined space rescue is a game of chance, NIOSH and OSHA studies reveal that hundreds of people have miscalculated their chance for survival in confined space operations. The objective for the student or rescuer is to recognize when the odds are stacked against them, and then to implement a change in the operation to increase the margin of safety, or stack the odds in their favor.

Our objective is to provide the student with the information on how to make legal and safe confined space entries and rescues, and provide them with realistic props and scenarios that make them stretch beyond what they may have previously considered their comfort zone. We believe strongly that without proper training attempting a confined space rescue would be betting on failure!

For further information on the confined space rescue program at Roseville Fire Department, call 916-774-5805.

By Kent Freeman ___________________________________________________________________

Confined Space Rescue Step-By-Step

Confined Space Rescue, by its very nature, is a dangerous venture. The hazards faced are not always obvious and can be very subtle and at the same time be extremely fatal. Statistics show that over 60% of those that die in confined spaces are people attempting to perform a rescue. These people did not recognize the hazards and miscalculated their abilities and resources. In a nutshell, they did not have a plan or step-by-step approach to affecting their rescue or making their entry.

The Occupational Safety & Health Administration (OSHA) requires that we assess the hazards prior to entry and that we complete a permit or checklist during the entry process. This permit or checklist assists us in making a systematic entry in which we provide for the safety of the entrant.

Very much like a permit or checklist, this article will go step-by-step through the tactical priorities of making a rescue entry, providing you with some insight on what the intent of OSHA is and whether the listed step is a mandatory component of your confined space entry program.

Size-up of the Incident
Every incident that we respond to should be sized up. Specific to confined space rescue, we should be thinking first of protecting our own rescue team, thus we should be looking closely at determining the hazards that exist. Many things will assist you in determining the hazards. The use of the space and what it normally contains can be a key. In addition, always ask the facility contact person for the initial entry permit if one was issued. This document will reveal all of the initial atmospheric monitoring results, the equipment in the space, how many entrants are in the space, the initial entrants entry time, the reason for the entry, etc. These are all key components of your size-up. Remember that not all information that should be logged on a permit gets written down as intended, sometimes because of laziness, and other times because of forgetfulness. With this in mind, it is always wise to question the facility contact person as to any hazards, etc. Although this is not listed in the confined space code as a mandatory component, it should be completed prior to every entry. Obviously knowing the facts makes the decision making process a lot easier.

Atmospheric Monitoring
This is very clearly a mandatory component of your confined space program. Statistics show us that the number one killer in confined spaces is the atmosphere. For this reason OSHA clearly requires that atmospheric monitoring be completed prior to entry and continuously and periodically while entrants are within the space.

The monitoring results must be done at all levels due to the possibility of stratified layers of hazardous gases. The regulation also states that the readings be done in four foot increments. Normally done at the top first, bottom second and then the middle levels. Monitoring will assist you to determine survival profile of the victim as well as the development of the ventilation program. Monitoring results must be documented on the permit or checklist.

Ventilation is listed in the OSHA regulations as a mandatory component of confined space entries. Many industries are actually required to calculate the number of complete air exchanges prior to entry. Ventilation for rescue purposes is greatly simplified. The regulation simply states that ventilation will be initiated prior to entry and be continued until all entrants are out of the space. Your ventilation will be achieved through either a process of natural, forced supply, forced exhaust or a combination of forced supply and exhaust ventilation. The intention is to first of all increase survival profile of the victim as well as make the environment more tenable for rescuers. Good ventilation procedures will buy you time, thus it should be initiated as soon after the initial monitoring results as possible.

The Entry Permit
As stated before, this document serves as your checklist to assist you in remembering all of the things that need to be done. Using and filling out the entry permit is mandatory, in addition canceling the permit is mandatory. (Canceling the permit is the act of signing and dating it at the completion of the operation.) Everyone knows one of OSHA's favorite quotes, "If it isn't documented, it didn't happen." The entry permit is your documentation. Key things which must be logged on the permit are; the monitoring results, use of the space and hazards, who is doing what, etc. The permit must be canceled at the completion of the entry and filed for at least one year.

The OSHA regulations on confined space entry clearly require that good communications must be provided between the entrant and the attendant. Just how the communications are carried out is not identified within the regulation.

I highly recommend that the primary communication plan and back-up plan be identified during the pre-entry briefing. Communications plans may include the use of portable radios, electronic hardwire systems, voice and hand signals, rope signals, light signals, personal alarm devices, as well as the use of tapping and rapping codes. Another thing to remember is that it is advisable for electronic devices to have an intrinsic safety rating for use in flammable atmospheres.

Respiratory Protection
While the provision for respiratory protection is not listed as a mandatory component of confined space entry programs, a more in depth look at the regulation will help to shed light on why it is not mandatory. The regulation was basically written for routine entries, this means that the expectation is that you will not be making entries into hazardous, or for that matter, even potentially hazardous environments. For routine entries this thorogh process makes sense, why require respiratory protection when no one should be entering a space that is hazardous. The problem is that we are entering for the purpose of "Rescue".

As informed rescuers, we know that the number one killer in confined spaces is hazardous atmospheres. With this in mind, it seems to me to be prudent to provide protection from what I know is the number one hazard. Many people will tell you that atmospheric monitoring will determine the need for respiratory protection. But, ask yourself these questions: 1) How many possible combinations of toxic gases did I check for with my atmospheric monitor? 2) How many possible combinations of toxic gases exist today, and of those combinations how many could be in the space that I'm preparing to enter with no respiratory protection?

Proper Harness
The regulations for Harnesses have been broadened to allow for a lot of options in this area. Commonly we see a Class III Harness with the connection point at the top of the back, at the shoulders or above the head with a spreader bar. The latest directives have stated this, "The entrant must be attached in a manner such that if they were to become unresponsive, they would create the smallest possible profile in the opening". The directive is meant to be performance oriented. When packaging your victim or placing a harness on yourself as a rescuer, ask yourself this question. If a person being placed in the harness was to become unresponsive, would it be possible to perform non-entry rescue or would the person roll into a ball or plug the opening? This question may prompt you to use anklets on even the rescuer when making horizontal entries.

Retrieval Lines
The regulation makes it clear in many areas that whenever we place a person in a confined space that they should be attached to a retrieval line. In fact, it specifically states that anytime an entrant enters a space below five feet below grade, they will be attached to a retrieval line. The over-riding objective for OSHA is to provide for non-entry rescue whenever possible. The regulation does allow for the entrant to disconnect from the retrieval line if the line increases their chances for injury or is impossible to keep attached. In addition, we like to send rescuers in on rope whenever possible. Rope allows us more flexibility, allowing for piggy-back systems etc.

Mechanical Device
The regulation requires a mechanical device to be provided to assist in hoisting the victim when entries are made five feet or more below grade. In this way one person can perform non-entry rescue. The regulation states that the mechanical device must be readily available, and does not specify what type of mechanical device or the specific mechanical advantage required. This allows us to use everything from cable winches with fall restraint to rope and pulley mechanical advantage systems in a z-rig fashion or piggy-back systems.

This is not directly considered to be a mandatory compliance issue, although the employer is directed to provide all equipment needed to complete the work or task. This is interpreted to include lighting if the space is too dark to see in. In addition, remember that whenever you put an electronic device in a confined space your should confirm that there is not a flammable atmosphere and or preferably use intrinsically safe equipment.

Pre-Entry Briefing
This component is not specifically identified in the regulation, but it only makes sense that you would want your key players (i.e., Entry Supervisor, Attendant, Entrant and Back-Up Entrant, at a minimum) to know the following things before they begin a risky task:

1. The hazards they may face in the space.
2. A confirmation of the equipment needed to complete the task and a confirmation of their 
    familiarity with the equipment.
3. A review of the communications plan and back-up plan.
4. Any self rescue plans as well as the objective to be met while in the space.

The Mandatory Positions
To make a safe and legal entry, certain positions must be filled, the regulation identifies these positions at a minimum:

• Entry Supervisor
• Attendant
• Entrant
• Back-up Entrant

Some other positions that might make your operation a lot safer and effective would be:

• Rigger to develop and manage the raise/lower system
• Air Supply Officer to manage the respiratory system
• Monitoring Officer to manage the monitoring and documentation of such
• Line tenders to manage all of the air, communications and retrieval lines

Remember the key is to extract the victim as quickly as possible in order to move them to an environment where they can be treated as a patient. In this process we must always remember that it is never acceptable to trade rescuers for victims, always look for the lowest risk options, and always perform thorough survival profile assessments prior to developing the rescue plan.

By Kent Freeman

Confined Space Rescue

Confined Space Rescue Programs—Questions and Answers
Without proper training and a thorough knowledge of the hazards involved, Confined Space Entry and especially Confined Space Rescue is a game of chance. NIOSH and OSHA studies reveal that hundreds of people have miscalculated their chance for survival in Confined Space operations.

The objective is to recognize when the odds are stacked against you, and then to implement a change in the operation to increase the margin of safety. Stated simply, you must be able to recognize when the odds are stacked against you, and when they are, you must implement a change in the operation to stack the deck in your favor.

Our objective in this presentation is to shed some light on what the Confined Space Regulations require and why. The regulations are written in order to provide a safe work environment for every day workers as well as rescuers. They are founded on thorough studies and statistics that were performed with the sole purpose of preventing injuries and deaths.
An intimate knowledge of the regulations will not tie your hands as many may lead you to believe. It will give you the knowledge to recognize when the odds are stacked against you, and will provide you the information to change the situation to increase the survival profile of your team and your victim.

Performing Confined Space Entries without the proper training and a thorough knowledge of the regulations would be betting on failure!

Questions and Answers
Over the past few years we have been asked any number of questions regarding developing and managing Confined Space Entry and Rescue teams. The following are a cross-section of some of the most prevalent asked questions: (The answers are based on our experience and the requirements set forth by Title 8 Sections 5156, 5157 and 5158 of the OSHA guidelines.

I work for a fire department, not a tank cleaning company or other type of industrial company, we have worked outside the scrutiny of OSHA on other aspects of our job by stating that our work was only for emergency purposes, why is this any different?

Fire departments routinely provide services in emergencies that cross over numerous trades and regulations. for years we have found ourselves in situations that required us to take stock of the situation and "Improvise and Overcome". In many cases this is the only way to successfully save a life, and there is no regulation that addresses how rescue would be performed in the specific trade or application that we have responded to. This is where confined space rescue clearly stands out. Title 8 Section 5156 specifically addresses the only operations and industries that are exempt from the confined space regulations covered in Title 8 Section 5157, and the Fire Service is not listed there. In addition, Section 5157 (k) specifically address the requirements of rescue and emergency services as it applies to confined spaces.
Thus, employees providing rescue or stand-by service for confined space entries must comply with the regulations set forth in Title 8 Section 5157.

I've read through Title 8 Sections 5156, 5157 and 5158 and they are terribly vague and hard to interpret. Why aren't they more specific? What are the mandatory components of a Confined Space Rescue program?

The regulation regarding confined space entry has been written trying to consider that there are many different trades, entering all sorts of spaces with any number of hazards, using all sorts of equipment. A code that is written too specifically would literally render many companies equipment obsolete. The vagueness in regulation actually works in our favor, take for example 5157 Section (K) (3) (B). It states that the other end of the retrieval line shall be attached to a mechanical device or fixed point outside the permit space... Imagine if it was more specific and stated that the cable must be attached to a cable winch capable of developing a 10 to 1 mechanical advantage. You then could not use the rope systems that you have become so accustomed to. The real problem is not that the regulation is vague, it is that its comprehensive, and that requires research to assure compliance. My suggestion is that if your not going to spend the time to assure compliance then you leave the job to someone who will, otherwise someone is going to get hurt or killed.

Many people would lead you to believe that the regulation was written to make your life miserable. Never forget this, it is written to preserve your life and it is based on numerous mistakes that cost someone else their life.

Now for the second part of the question. It is difficult to condense the material covered in roughly 15 pages to a few mandatory components but I never fail to have this question asked when I present information. First of all, let me make a disclaimer, and that is that you must do your own research to have a thorough knowledge of the code, but briefly you must provide at a minimum the following positions at a confined space entry/rescue.

· Entry/Rescue Supervisor
· Attendant
· Entrant
· Back-up Entrant

Other positions you may like to activate if personnel exist would be:

· Monitoring Officer
· Rigger
· Air-Supply Officer
· Line Tender
· Ventilation Officer
· Safety Officer

In addition, to following components must be present:
· Written policy (including the permit program)
· Provide for rescue or stand-by service
· Atmospheric monitoring
· Ventilation
· Retrieval line
· Appropriate harness
· Mechanical device (advantage)
· Communications

The following components may also be mandatory if conditions dictate but in some cases are optional:

· Lighting
· Respiratory protection

We have a U.S.A.R. (Urban Search and Rescue) Team in our department and they been assigned to handle confined space incidents. They obviously will comply with the criteria in the regulations won't they?

Not necessarily, while much of the training a U.S.A.R. team performs will be advantageous in a confined space incident it doesn't mean that they will comply with the guidelines set forth in Title 8 Sections 5157 (and specifically Section K). Basically they would have to be trained so that they have the understanding, knowledge and skills necessary for the position they will hold. (i.e. entrant, attendant, entry supervisor, etc.). You must review the duties of each position as listed in the regulation to confirm that this training has taken lace. Following an incident it is not rare for training records to be reviewed as well as the credentials of the instructor to be reviewed. In addition Section 5157 K, L and C states that each member of the rescue service shall practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins or actual persons from actual permit spaces or representative permit spaces. It goes on to state that the representative spaces must actually simulate the spaces we are going to enter in regards to the opening size, configuration and accessibility. this section of the regulation clearly requires anyone playing an integral part of a confined space rescue to have previously trained specifically in confined spaces annually.

Many of the violations/citations issued have to do with the failure to provide and document training. If you confirm and document that your employees have been trained on the hazards they may face, equipped with appropriate equipment and trained on the equipment, then you will be going a long way towards having a program that complies with the regulation.

We have had contractors call our Fire Department and request our services for confined space rescue, are we required to provide this service?

No. There is nothing that says that a Fire Department has to provide the service of confined space rescue. In fact, if you department is not trained and equipped to provide the service, you definitely want to make it clear that you don't perform confined space rescues.
Confined space rescue is much like hazardous materials in the respect that many Fire Departments opt to develop Hazardous Materials Response Teams in which they provide the equipment and training to a segment of their organization. In this way they comply with the regulations mandating Hz-Mat operations and they are capable of handling these specialized incidents. Other Fire Departments opt not to pursue the service of hazardous materials mitigation, and they develop agreements with surrounding Fire Departments that do have Hz-Mat Teams. Confined space rescue is no different.
The key is to remember that you are going to ultimately end up with one of these incidents in ;your jurisdiction, you'll be well served to have developed an agreement ahead of time with a department that can provide this service.

If a contractor or company calls us to provide rescue service for a confined space entry, and we agree, are we required to stand-by at the site and what are the contractors or companies responsibilities?

First of all, you are not required to be on site unless that is part of your agreement with the company. It is the responsibility of the company to provide for the safety of their employees, they must determine if your response time will place their employees in jeopardy, and if so, make accommodations. In addition, the company must:
· apprise you of any hazards you may face if you are required to make an entry,
· allow you to inspect or pre-plan the spaces you may be needed to enter into,
· allow you to train in the spaces prior to standing by, if you choose to.

we are developing a Confined Space Rescue Team, what is the minimum amount of people required to perform a confined space rescue?

The best way to answer this question for yourself is to actually perform some training rescues. While you're doing this, make sure that you are providing for monitoring, ventilation, communications, a retrieval system, maintaining a count and the condition of the entrant, as well as maintaining their respiratory air etc.
The point is this, the regulation is written in a way that you could literally perform a rescue with only three personnel, although this may comply, it would not be prudent nor effective given the amount of tasks that need to be done practically at the same time.

Regarding atmospheric monitoring or testing, the regulation states that the space to be entered should be tested prior to the entrant entering and monitored continuously and periodically as long as the entrant is in the space. How often is periodically?

The frequency of atmospheric testing will depend on numerous factors, what was the initial readings at every level, was anything outside the norm? This would cause an increase in frequency of testing, what are the potential atmospheric hazards that have been identified in the space. Is the rescuer going in without respiratory protection? Is the victim unresponsive? How effective is your ventilation efforts? All of these are factors that would cause me to be continuously monitoring the atmosphere at every level.

Let's not forget why we were summoned to the scene in the first place, because someone didn't come out of the space as planned. If we couple that fact with the fact that hazardous atmospheres are the number one killer in confined spaces, we make a pretty compelling argument for monitoring continuously at every level with little to no pauses.

Remember, confined space atmospheres are dynamic due to variables such as temperature, pressure, physical characteristics of the material posing the hazard, ventilation, movement within the space etc.

For routine industry entries it is not rare to see fifteen minute increments on atmosphere testing, for rescue applications increments must be kept considerably shorter.

We are in the process of developing our confined space rescue program, where do we request or order the permits needed to document our entries?

Entry permits are developed or adapted by each employer to serve their specific needs. They are not requested from any government office nor are they forwarded there following entries. The permits should serve the purpose to document many different components of the entry. Some examples would be the number and identities of the persons entering the space, the atmospheric monitoring results, a description of the space, time and date etc. There are sample copies of entry permits in the appendix of Title8 Section 5157. When developing a permit for your own purpose try to make it as simple and easy to use as possible so that your employees will not be intimidated or frustrated with using it. At the same time, you want to be sure that it is comprehensive enough to remind your personnel of everything they need to do and document the things that need to be documented.

Entry permits basically serve two purposes. First, to document the entry and provide proof that the requirements of the regulation are met, and secondly, to serve as a checklist to remind the Confined Space Entry Team of the tasks that must be performed and equipment that must be provided to reduce or eliminate hazards. Remember your permits must be retained for one year following entries and an annual review of your program should be done also.

By Kent Freeman